The Government have stuck to their commitment to consult on targets for packaging waste in time for them to be introduced at the budget. They have indicated that their preferred option is to increase the statutory targets on aluminium, plastic and steel by 3%, 5% and 1% respectively and split the glass target by end-use. Increasing targets on both aluminium and glass makes sense both from a carbon perspective and bringing parity in targets amongst the major packaging materials. However concerns have been raised within the reprocessing industries that increased targets will give rise to both lower quality and increased export. In aluminium in particular judging the impact of ‘end of waste’ criteria and therefore who might be eligible to issue the PRN is proving challenging. Despite these concerns these increased targets are to be welcomed. From a growth and therefore PRN cost perspective none of these challenges seem insurmountable and while PRN costs in both materials will increase there is nothing at this stage to suggest price increases will be exponential.

The splitting of the glass target has interesting implications and may have unintended consequences. It will remain important that the re-melt target is a minimum while the aggregate target is a maximum sub-element of the overall glass target. So that obligated companies could if they wished meet their obligation by solely purchasing re-melt glass PRNs but could not do so by solely purchasing aggregate glass PRNs.

The regulators and data remain important issues. In particular the regulators must show capability, consistency and competence in applying and enforcing the regulations. Quality is a broad ranging subject and covers a multitude of regulations but from a packaging perspective it is quite conceivable that material that meets both the end of waste and transfrontier shipment of waste regulations criteria is not 100% packaging and therefore PRNs or PERNs should only be issued on a proportion of them. If the proportion of the blend of packaging in the material is misjudged so there is the potential for an excess of PRNs to be issued in which case the price will remain at its current administrative levels.

Data is a perennial problem, although its quality has improved immensely courtesy of the National Packaging Waste Database. One of the most frequent complaints about the regulations is the amount of effort that is needed to gather the data to submit to comply with the regulations. However if a business does not gather and thereafter continue to monitor the quantity of packaging that it uses how can it possibly know whether that packaging is increasing or decreasing? This must continue to be an important role for compliance schemes. In many ways the regulations are a victim of their own success if the cost per packaging item was greater there would be less concerns about the quantity of time that it takes to gather the data.

Although data submitted by companies is an important driver for the PRN market it is also a guide as to how much growth or otherwise there is in packaging placed on the market which is the most important figure for the UK to show they are complying with the directive. It is always surprising that there is little correlation between the two figures with some materials, aluminium being apparently consistently over-reported and others such as steel and glass being so consistently under-reported.

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